EU Battery Regulation 2023/1542 — Digital Passport Compliance.
How to comply before the 18 February 2027 date. AI proposes values for the Annex XIII fields your existing documents contain, for your team to approve, and Traceable generates a GS1 Digital Link QR code for products with a GTIN. From 18 February 2027 you must also upload each battery's unique identifier to the registry set up under ESPR Article 13 (Article 77(10)). Traceable prepares the registration file you upload in your own registry session; as of 26 September 2026 the registry does not yet accept battery registrations.
4 months remaining
At a glance
EU Battery Regulation 2023/1542 requires a Battery Passport for every EV, LMT, and industrial battery above 2 kWh placed on the EU market or put into service from 18 February 2027 (Article 77(1)). The Commission guidance of 15 August 2026 enumerates 71 data points, of which 47 are mandatory for EV batteries at that date, covering identification, chemistry and materials, performance and durability, dismantling and end-of-life data. The passport is reached through a QR code; some of it is public, and the rest is restricted to persons with a legitimate interest, notified bodies, market surveillance authorities and the Commission (Annex XIII).
- Mandatory from 18 February 2027 for EV, LMT, and industrial batteries above 2 kWh.
- 71 data points in the Commission guidance; 47 mandatory for EV at February 2027.
- Carbon footprint declaration is not to be filled or displayed at February 2027, pending the format implementing act.
- Article 77(3) requires the QR code and unique identifier to comply with the ISO/IEC 15459 series.
- Portable and SLI batteries have no battery passport obligation under Article 77(1).
What Regulation 2023/1542 requires
Annex XIII data fields
Commission guidance (Version 2.0, 15 August 2026) lists 71 data points: 47 mandatory for EV, 50 for LMT and 32 for industrial batteries above 2 kWh at February 2027, covering identification, materials, performance, durability and dismantling.
QR code and unique identifier
Machine-readable identifier on every battery.
Supply chain due diligence
From 18 August 2027 (Article 48(1)), operators above the Article 47 turnover threshold need a chain of custody or traceability system for the Annex X raw materials (Article 49(1)(d)).
ESPR DPP Registry (Article 13)
From 18 February 2027, Article 77(10) requires you to upload each battery's unique identifier to the registry set up under ESPR Article 13. As of 26 September 2026 the registry does not yet accept battery registrations. Traceable's EU Registry Readiness page prepares the file you upload in your own registry session.
How the AI engine handles battery compliance
Upload your IEC certificates, UN 38.3 test reports, carbon footprint studies and BOMs. AI proposes values for the Annex XIII fields they contain, each with a High, Medium or Low confidence rating, for your team to approve. AI document extraction is billed separately, based on the number of documents processed.
See how the AI extraction works →
Your compliance score updates as approved values are saved, and the required fields still missing are listed, so you can close gaps before you publish.
Suppliers answer your data requests in the portal. You approve each answer before you enter it in the passport, and every response is recorded in the audit log.
For your compliance team
Per published passport, falling to €6 or below at higher volumes. Pay-as-you-go is €18.
Free trial at no cost. AI document extraction is billed separately, based on the number of documents processed.
Priced per published passport, with a one-time €2,000 activation fee on Starter, Growth and Scale.
For certification bodies
Verification built in — not bolted on.
On Scale and above, certification bodies use the Verifier portal to review the documents and claims you submit and attest on the record, with a tamper-evident audit trail, instead of exported PDFs and email threads.
Documents and claims awaiting your review arrive in one queue, newest first.
Every AI-proposed value carries a High, Medium or Low confidence rating, and a person approves it.
Every action timestamped. Every decision recorded. Fully auditable.
Cathode active material suppliers sign in to the supplier portal with a one-time email code, answer your structured data requests and upload certificates. Each answer goes only to the manufacturer that asked for it.
On Scale and above, certification bodies sign in to the Verifier portal to review and attest your battery records directly, with a tamper-evident audit trail. No exported PDFs. No back-and-forth emails.
Traceable covers batteries and textiles. The same platform handles EU Battery Regulation passports and textile passports, so one account covers both.
Free resource
EU Battery Passport Checklist — Annex XIII
A data readiness checklist for the battery passport, organised by data category, with a link to the directory of all 71 data points. Use it in supplier conversations, internal reviews and audit preparation.
Battery Passport — Common Questions
Yes for the regulation, no for the passport. Portable batteries are in scope of EU Battery Regulation 2023/1542, but Article 77(1) sets the battery passport obligation only for LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh, from 18 February 2027, and no provision of the Regulation sets a passport date for portable batteries. From 18 February 2027 every battery, portable ones included, must carry a QR code (Article 13(6)); for a portable battery it gives access to the information listed in Article 13(6)(b). On classification: Article 3(1), point (9), makes portable a residual category, meaning sealed, weighing 5 kg or less, not designed specifically for industrial use, and not an electric vehicle, LMT or SLI battery. All four conditions must hold, so a sealed 4 kg pack that powers an e-scooter is an LMT battery, not a portable one. Confirm applicability with legal counsel before relying on this.
Annex XIII is the schedule in EU Battery Regulation 2023/1542 that lists every data field a Battery Passport must contain. It is organised as four numbered points, each one an access tier, and covers general information (manufacturer, model, chemistry), carbon footprint, recycled content, performance and durability, hazardous substances, supply-chain due diligence, and end-of-life handling instructions. European Commission guidance of 15 August 2026 enumerates 71 data points across those points, of which 47 are mandatory for EV batteries at February 2027, 50 for LMT and 32 for industrial above 2 kWh.
Regulation (EU) 2023/1542 does not create a separate EU Battery Registry. Under Article 77(10) the economic operator placing the battery on the market or putting it into service must upload the unique identifier into the registry referred to in Article 13(1) of the ESPR, Regulation (EU) 2024/1781, which required the Commission to set that registry up by 19 July 2026. Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026 and in force since 6 August 2026, lays down how the registry works. As of 26 September 2026 the registry does not yet accept battery registrations; the upload becomes mandatory with the passport on 18 February 2027. Traceable's EU Registry Readiness page prepares the registration file that you upload in your own registry session. The QR code on your product is unaffected either way.
No. Article 77(3) of EU Battery Regulation 2023/1542 requires the QR code and the unique identifier to comply with the ISO/IEC 15459 series or their equivalent, and it does not name GS1. A GS1 GTIN is one widely used option, not a legal requirement. On Traceable, a product with a GTIN gets a QR code in GS1 Digital Link format; if you want GTINs and do not yet have a GS1 company prefix, you register through your national GS1 member organisation.
A battery carbon footprint declaration is a document required by Article 7(1) of EU Battery Regulation 2023/1542 for each battery model per manufacturing plant, stating the carbon footprint in kg of carbon dioxide equivalent per kWh of the total energy the battery provides over its expected service life. For EV batteries it applies from 18 February 2025 or 12 months after the methodology delegated act or the format implementing act enters into force, whichever is later. Neither act had been adopted as of 26 September 2026, so the declaration does not yet apply, and the Commission guidance marks the carbon footprint data points as not to be filled or displayed at February 2027.
Further reading
Regulatory Guide
EU Battery Regulation 2023/1542 — Full Guide
Scope, Annex XIII fields, carbon footprint timeline, and all Article 77 obligations — the primary reference for battery manufacturers.
Regulatory Guide
GS1 Digital Link — QR Code Standard
How the ISO/IEC 18975 standard works, what EU law does and does not require of a passport QR code, and how to generate one.
Regulatory Guide
What Is a Digital Product Passport?
The foundational explainer — definition, data tiers, lifecycle scope, and how the passport follows a product from manufacture to recycling.
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